In a Decision – S.R. v D.P. (an "Unreported Decision") >> the Court Held:
The Appellate Division determined that the Trial Court’s decision to deny the Father Joint Legal Custody of his daughter and the continuation of sole legal and physical custody was warranted, notwithstanding that the Father never explicitly consented to the creation of a parent-child relationship between child and aunt and uncle.
The father’s lack of involvement in child’s life was due to Father’s own limited aspirations. The original order granting temporary residential custody to aunt allowed him unsupervised visitation but he never took child to the doctor nor to school activities. Additionally, his testimony showed that if he were awarded custody, he intended to phase aunt and uncle out of child’s life despite the fact that child had formed a parental bond with them.